Global Privacy Policy

We at The Tradesmen’s Collective (the “Tradesmen’s”) respect and protect the privacy of visitors to our websites and our customers. This Privacy Policy describes our information handling practices when you access our services, which include our content on the websites located at www.thetradesmens.com, or any other websites, pages, features, or content we own or operate (collectively, the"Site(s)") or when you use the Tradesmen’s mobile app, or third party applications relying on such an API, and related services (referred to collectively hereinafter as "Services").

1.ACCEPTANCE OF THIS PRIVACY POLICY

By accessing and using our Services, you signify acceptance to the terms of thisPrivacy Policy. Where we require your consent to process your personalinformation, we will ask for your consent to the collection, use, and disclosure of your personal information as described further below. We may provide additional "just-in-time" disclosures or information about the data processing practices of specific Services. These notices may supplement or clarify our privacy practices or may provide you with additional choices about how we process your data.

If you do not agree with or you are not comfortable with any aspect of this Privacy Policy, you should immediately discontinue access or use of our Services.

2. THE PERSONAL INFORMATION WE COLLECT

Personal information is typically data that identifies an individual or relates to an identifiable individual. This includes information you provide to us, information which is collected about you automatically, and information we obtain from third parties. The definition of personal information depends on the applicable law based on your physical location. Only the definition tha tapplies to your physical location will apply to you under this Privacy Policy.

 

Information you provide to us. To establish an account and access our Services, we'll ask you to provide us with some important information about yourself. This information is either required bylaw (e.g. to verify your identity), necessary to provide the requested services(e.g. you will need to provide your bank account number if you'd like to link that account to use Escrow Services), or is relevant for certain specified purposes, described in greater detail below. As we add new features andServices, you may be asked to provide additional information.

If you choose not to share certain information with us, we may not be able to serve you as effectively or offer you our Services. Any information you provide to us that is not required is voluntary.

We may collect the following types of information from you:

  • PersonalIdentification Information: Full name, date of birth, nationality, gender, signature, utility bills, photographs, phone number, home address, email, business address, business name(s), and/or license number(s).
  • FormalIdentification Information: Government issued identity document such asPassport, Driver's License, National Identity Card, State ID Card, Tax ID number, passport number, driver's license details, national identity card details, visa information, and/or any other information deemed necessary to comply with our legal obligations under financial or anti-money laundering laws.
  • Institutional Information: Employer Identification number (or comparable number issued by a government), proof of legal formation (e.g. Articles of Incorporation),personal identification information for all material beneficial owners.
  • FinancialInformation: Bank account information, payment card primary account number(PAN), transaction history, and/or tax identification.
  • TransactionInformation: Information about the transactions you make on our Services, such as the name of the recipient, your name, the amount, and/or timestamp.
  • EmploymentInformation: Office location, job title, and/or description of role.
  • Correspondence: Survey responses, information provided to our support team or user research team.
  • Audio, electronic, visual and similar information, such as call and video recordings.

Information we collect from you automatically. To the extent permitted under the applicable law, we may collect certain types of information automatically, such as whenever you interact with the Sites or use the Services. This information helps us address customer support issues, improve the performance of our Sites and Services, provide you with a streamlined and personalized experience, and protect your account from fraud by detecting unauthorized access. Information collected automatically includes:

  • Online Identifiers: Geolocation/tracking details, browser fingerprint, operating system, browser nameand version, and/or personal IP addresses
  • Usage Data:Authentication data, security questions, click-stream data, public socialnetworking posts, and other data collected via cookies and similar technologies.

For example, we mayautomatically receive and record the following information on our server logs:

  • How you came to and usethe Services;
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  • Device type and uniquedevice identification numbers;
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  • Device eventinformation (such as crashes, system activity and hardware settings, browsertype, browser language, the date and time of your request and referral URL);
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  • How your deviceinteracts with our Sites and Services, including pages accessed and linksclicked;
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  • Broad geographiclocation (e.g. country or city-level location); and
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  • Other technical datacollected through cookies, pixel tags and other similar technologies thatuniquely identify your browser.
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  • We may also useidentifiers to recognize you when you access our Sites via an external link,such as a link appearing on a third-party site.

Informationwe collect from our affiliates and third parties. From time to time, we may obtain informationabout you from our affiliates or third-party sources as required or permittedby applicable law. These sources may include:

  • Our Tradesmen’s Familyof Companies: Our “family of companies” is the group of companies related to usby common control or ownership (“Affiliates”). In accordance with applicablelaw, we may obtain information about you from our Affiliates as a normal partof conducting business, if you link your various Tradesmen’s accounts (e.g., TheTradesmen’s Collective Escrow Services, LLC), so that we may offer ourAffiliates’ Services to you.
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  • Public Databases,Credit Bureaus & ID Verification Partners: We obtain information about youfrom public databases and ID verification partners for purposes of verifyingyour identity in accordance with applicable law. ID verification partners canuse a combination of government records and publicly available informationabout you to verify your identity. Such information may include your name,address, job role, public employment profile, credit history, status on anysanctions lists maintained by public authorities, and other relevant data. We obtainsuch information to comply with our legal obligations, such as anti-moneylaundering laws. In some cases, we may process additional data about you toassess risk and ensure our Services are not used fraudulently or for otherillicit activities. In such instances, processing is necessary for us tocontinue to perform our contractual obligations with you and others.
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  • Blockchain Data: We mayanalyze public blockchain data to ensure parties utilizing our Services are notengaged in illegal or prohibited activity under our Terms, and to analyzetransaction trends for research and development purposes.
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  • Joint MarketingPartners & Resellers: For example, unless prohibited by applicable law,joint marketing partners or resellers may share information about you with usso that we can better understand which of our Services may be of interest toyou.
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  • Advertising Networks& Analytics Providers: We work with these providers to provide us withde-identified information about how you found our Sites and how you interactwith the Sites and Services. This information may be collected prior to accountcreation.

3. ANONYMIZED ANDAGGREGATED DATA

Anonymizationis a data processing technique that modifies personal information so that itcannot be associated with a specific individual. Except for this section, noneof the other provisions of this Privacy Policy applies to anonymized oraggregated customer data (i.e. information about our customers that we combinetogether so that it no longer identifies or references an individual customer).

 

 

TheTradesmen’s may use anonymized or aggregate customer data for any businesspurpose, including to better understand customer needs and behaviors, improveour Services, conduct business intelligence and marketing, and detect securitythreats. We may perform our own analytics on anonymized data or enableanalytics provided by third parties.

 

Types of data we mayanonymize include, transaction data, click-stream data, performance metrics,and fraud indicators.

4.HOW YOUR PERSONAL INFORMATION IS USED

 

 

1)To maintain legal and regulatory compliance

 

Mostof our core Services are subject to laws and regulations requiring us tocollect, use, and store your personal information in certain ways. For example,the Tradesmen’s must identify and verify customers using our Services in orderto comply with anti-money laundering laws across jurisdictions. This includescollection and storage of your photo identification. In addition, we use thirdparties to verify your identity by comparing the personal information youprovide against third-party databases and public records. When you seek to linka bank account to your Tradesmen’s Account, we may require you to provideadditional information which we may use in collaboration with service providersacting on our behalf to verify your identity or address, and/or to manage riskas required under applicable law. If you do not provide personal informationrequired by law, we will have to close your account.

 

2)To enforce our terms in our user agreement and other agreements

 

TheTradesmen’s handles sensitive information, such as your identification andfinancial data, so it is very important for us and our customers that weactively monitor, investigate, prevent, and mitigate any potentially prohibitedor illegal activities, enforce our agreements with third parties, and/orprevent and detect violations of our posted user agreement or agreements forother Services. In addition, we may need to collect fees based on your use ofour Services. We collect information about your account usage and closelymonitor your interactions with our Services. We may use any of your personalinformation collected for these purposes. The consequences of not processingyour personal information for such purposes is the termination of your account.

 

3)To detect and prevent fraud and/or funds loss

 

Weprocess your personal information in order to help detect, prevent, andmitigate fraud and abuse of our services and to protect you against accountcompromise or funds loss.

 

4)To provide the Tradesmen’s Services

 

Weprocess your personal information to provide the Services to you. For example,when you want to store data, photos and/or documents on our platform, werequire certain information such as your identification, contact information,and payment information. We cannot provide you with Services without suchinformation. Third parties such as identity verification services may alsoaccess and/or collect your personal information when providing identityverification and/or fraud prevention services.

 

 

 

5)To provide Service communications

 

Wesend administrative or account-related information to you to keep you updatedabout our Services, inform you of relevant security issues or updates, orprovide other transaction-related information. Without such communications, youmay not be aware of important developments relating to your account that mayaffect how you can use our Services. You may not opt-out of receiving criticalservice communications, such as emails or mobile notifications sent for legalor security purposes.

 

6)To provide customer service

 

Weprocess your personal information when you contact us to resolve any questions,disputes, collect fees, or to troubleshoot problems. Without processing yourpersonal information for such purposes, we cannot respond to your requests andensure your uninterrupted use of the Services.

 

7)To ensure quality control

 

Weprocess your personal information for quality control and staff training tomake sure we continue to provide you with accurate information. If we do notprocess personal information for quality control purposes, you may experienceissues on the Services such as inaccurate transaction records or otherinterruptions.

 

8)To ensure network and information security

 

Weprocess your personal information in order to enhance security, monitor andverify identity or service access, combat spam or other malware or securityrisks and to comply with applicable security laws and regulations. The threatlandscape on the internet is constantly evolving, which makes it more importantthan ever that we have accurate and up-to-date information about your use ofour Services. Without processing your personal information, we may not be ableto ensure the security of our Services.

 

9)For research and development purposes

 

Weprocess your personal information to better understand the way you use andinteract with the Tradesmen’s Services. In addition, we use such information tocustomize, measure, and improve the Tradesmen’s Services and the content andlayout of our website and applications, and to develop new services. Withoutsuch processing, we cannot ensure your continued enjoyment of our Services.

 

10)To enhance your experience

 

Weprocess your personal information to provide a personalized experience, andimplement the preferences you request. For example, you may choose to provideus with access to certain personal information stored by third parties. Withoutsuch processing, we may not be able to ensure your continued enjoyment of partor all of our Services.

 

11)To facilitate corporate acquisitions, mergers, or transactions

 

Wemay process any information regarding your account and use of our Services asis necessary in the context of corporate acquisitions, mergers, or othercorporate transactions.

 

 

 

 

 

 

12)To engage in marketing activities

 

Basedon your communication preferences, we may send you marketing communications(e.g. emails or mobile notifications) to inform you about our events or ourpartner events; to deliver targeted marketing; and to provide you withpromotional offers. Our marketing will be conducted in accordance with youradvertising marketing preferences and as permitted by applicable law.

 

13)To protect the health and safety of our employees and visitors, our facilitiesand our property and other rights. If you visit one of our locations, tomaintain security at such locations you may be photographed or videotaped.

 

14)For any purpose that you provide your consent.

 

We will not use yourpersonal information for purposes other than those purposes we have disclosedto you, without your permission. From time to time, and as required under theapplicable law, we may request your permission to allow us to share yourpersonal information with third parties. In such instances, you may opt out ofhaving your personal information shared with third-parties, or allowing us touse your personal information for any purpose that is incompatible with thepurposes for which we originally collected it or subsequently obtained yourauthorization. If you choose to limit the use of your personal information,certain features or Tradesmen’s Services may not be available to you.

5.LEGAL BASES FOR PROCESSING YOUR INFORMATION

 

Forindividuals who are located in the European Economic Area, the United Kingdomor Switzerland (collectively “EEA Residents'') at the time their personalinformation is collected, our legal bases for processing your information underthe EU General Data Protection Regulation (“GDPR”) will depend on the personalinformation at issue, the specific context in the which the personalinformation is collected and the purposes for which it is used. We generally onlyprocess your data where we are legally required to, where processing isnecessary to perform any contracts we entered with you (or to take steps atyour request prior to entering into a contract with you), where processing isin our legitimate interests to operate our business and not overridden by yourdata protection interests or fundamental rights and freedoms, or where we haveobtained your consent to do so. In some rare instances, we may need to processyour personal information to protect your vital interests or those of anotherperson. Below is a list of how the Tradesmen’s uses your personal information,as described above, with the corresponding legal bases for processing. If youhave questions about or need further information concerning the legal basis onwhich we collect and use your personal information, please contact us using thecontact details provided under the "How to contact us" heading below.

 

6.WHY WE SHARE PERSONAL INFORMATION WITH OTHER PARTIES

 

Wetake care to allow your personal information to be accessed only by those whorequire access to perform their tasks and duties, and to share only with thirdparties who have a legitimate purpose for accessing it. The Tradesmen’s willnever sell or rent your personal information to third parties without yourexplicit consent. We will only share your information in the followingcircumstances:

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